Last edited on: 21 March 2019
Valid as of: 21 March 2019
The controller of NoHo Partners Group’s Whistleblowing channel is the Finnish restaurant industry group NoHo Partners Plc (business ID: 1952494-7).
1. The purpose of processing personal data
In its operations, NoHo Partners Plc complies with honest principles and aims at continuously ensuring that there is no misconduct in its operations. The whistleblowing channel is used to report market abuse. The purpose of this is to promote complying with corporate governance and ethical principles, identify misconduct and encourage everyone to report misconduct and suspected misconduct. The processing of personal data is based on the enforcement of a contract and the legitimate interest of NoHo Partners Group; conducting business.
2. Data file content
When reporting suspected misconduct, the system asks to submit the name of the person to be reported and a detailed description of the misuse, misconduct, suspicion or possible dishonest activities (how, where and when it has occurred). The reports are given anonymously but if they so wish, the reporter can give their own email address and telephone number by using the form. The data file may also contain other data that may be considered necessary for investigating reported misconduct, thus having a legitimate interest for storage.
3. Regular data sources
The data file comprises data submitted by the person reporting the suspected misconduct on a form in the whistleblowing channel and of information created during NoHo Partners Group’s investigation into the report that are necessary on order to investigate the reported misconduct.
4. Regular disclosures of data
All the data necessary for investigating any reported misconduct are processed internally at NoHo Partners Group. If data must be processed outside of NoHo Partners Group due to investigative reasons, the data will be disclosed directly to the investigating party taking into account the necessity requirement.
5. Transfer of data outside the EU or EEA
Content of the data file is not regularly disclosed to a location outside of the EU or EEA.
6. Principles of protecting the data file
Manual material: The goal is to keep the amount of manual material at a minimum. Data is stored on the locked premises of NoHo Partners Group. A hard copy which is necessary for investigating the reported misconduct is processed carefully and destroyed once its purpose of use is over.
Electronic material: The content of the data file is only processed by people whose work requires it. Access to the data file is restricted with personal user names and passwords. SSL protected connections are used in Internet-based services.
7. Storing personal data
Data will be stored for as long as is necessary in order to take care of duties in accordance with the purpose of use.
8. Right to be informed and right to rectification
In accordance with the Personal Data Act, the data subject has the right to review the data concerning them stored in the data file. The data subject has the right to demand the rectification, erasure and completion of erroneous data concerning them.
9. Other rights related to the processing of personal data
The data subject has the right to object to the processing of their personal data.
10. Contact details
NoHo Partners Plc
Hatanpään valtatie 1 B
FI-33100 Tampere, Finland